SC on ‘sweetheart theory’: Relationship no defense for rape

MANILA — The Supreme Court convicted an adult man of raping a 14-year old girl and emphasized that love does not justify rape, even if two individuals are supposedly in a relationship.

In the decision of the 2nd Division promulgated on February 3, 2025, the court modified the decision of the Court of Appeals, which convicted the accused of the crime of sexual abuse for violating Republic Act No. 7610 — the Special Protection of Children Against Child Abuse, Exploitation and Discrimination Act.

The high court convicted the accused of rape under the Revised Penal Code and ordered him to pay the complainant a total of P225,000 as civil indemnity and damages.

Supreme Court says genital contact not required to prove attempted rape

COERCED INTO SEXUAL INTERCOURSE

The case stemmed from an incident in 2003 when the accused visited the complainant and insisted on having sexual intercourse.

The accused threatened the girl that if she did not give in, he would show her relatives a video of them kissing.

The Supreme Court noted that the totality of the arguments of the accused revolved around the “sweetheart defense”, which argues that they were in a relationship and that sex was consensual.

According to past court decisions, the "sweetheart defense" requires proof of a relationship and proof of consent.

During trial at the Regional Trial Court, the accused said he did not coerce the complainant as they were in a romantic relationship.

The RTC found the accused guilty of sexual abuse, which was later on upheld by the Court of Appeals.

The accused brought the case to the Supreme Court, which “rectified” the decision of the lower courts and convicted him of rape.

“As further proven by the records, petitioner, who was senior to the victim by four years, manipulated and subjected her to molestation, under the threat of ruining her reputation by exposing her explicit video to her relatives,” the court said in the decision penned by Associate Justice Jhosep Lopez.

SC: THERE WAS NO CONSENT FROM VICTIM

SC says victim’s past sexual activity not admissible as evidence in abuse cases

The court stressed that the “sweetheart theory” cannot be given credence because of the lack of consent from the complainant.

“While this Court cannot close its eyes to the sexual predisposition and awareness of this generation's youth, its duty to uphold the welfare and protection of children against any and all forms of abuse still remains,” the court said.